Privacy Policy

HA-LU Inc. (the "Company") has established the following privacy policy (this "Policy") regarding the personal information of customers that the Company handles in the course of its content production and business operations.

Business Operator Handling Personal Information

Name: HA-LU Inc.
Address: Chez Irene Bldg. 2F, 7-4-7 Akasaka, Minato-ku, Tokyo 107-0052, Japan
Representative Director: Haruto Oka
Established: April 30, 2024

Article 1: Method of Obtaining Personal Information

When obtaining personal information, the Company will publicly announce or notify the purpose of use (including announcement through this Policy) and will obtain personal information by lawful and fair means in accordance with the following methods.

1. Having customers provide information necessary for the Company's content production and business operations

2. Having information provided by other services when customers permit linkage with such services

3. Obtaining information independently when customers use the Company's services

4. Obtaining information based on the individual consent of customers

5. Having customers provide information directly or through written documents or other media

Article 2: Purpose of Use

The Company will use personal information obtained from customers for the following purposes.

1. Operation of events, seminars, etc. Holding, operating and managing events, seminars, etc.; providing participant information to co-hosting and sponsoring companies; providing information from the Company, casual interviews and scouting information; providing information on products, services, events and seminars of partner companies; operating and managing campaigns, etc.; sending and managing questionnaires, paying rewards and sending goods

2. Responding to inquiries Responding to various inquiries; improving the quality of inquiry responses and accurately understanding their content (including recording of calls)

3. Recruitment Considering and deciding on employment conditions and hiring, confirming application history, and investigating work history and background; responding to inquiries, administrative communication and other procedures necessary for recruitment screening; providing guidance on matters necessary for joining the Company after a hiring decision and other necessary procedures; improving recruitment activities using data obtained by analyzing acquired information; personnel and labor management after joining; personal information of applicants not hired is retained for a certain period after the end of screening and then disposed of appropriately

4. Business partner information Selecting business partners, contract procedures, managing business partners and performing related operations; providing information on the Company's services and other useful information

Article 3: Security Control Measures

The Company will endeavor to keep customers' personal data accurate and up to date, and will take necessary and appropriate security control measures to protect it from unauthorized access, alteration, leakage, loss and damage.

Article 4: Provision to Third Parties

The Company will not provide personal data it handles to third parties (including those located outside Japan) without obtaining the customer's prior consent, except in the following cases.

1. When entrusting the handling of personal data within the scope necessary to achieve the purpose of use

2. When personal data is provided in connection with the succession of business due to a merger or other reasons

3. When cooperating with a national or local government agency, or a party entrusted by them, in carrying out affairs prescribed by laws and regulations

4. When permitted by laws and regulations

Article 5: Outsourcing

The Company may outsource work to third parties in order to provide its services and, in doing so, may provide part or all of the personal data it holds. In such cases, the Company will appropriately supervise the contractor so that appropriate security control measures for personal information are taken.

Article 6: Disclosure of Personal Data

When requested by a customer to disclose personal data in accordance with the Act on the Protection of Personal Information, the Company will, after confirming that the request is made by the customer in person, disclose the data without delay (if the personal data does not exist, the Company will notify the customer to that effect). However, this does not apply when the Company is not obligated to disclose under the Act on the Protection of Personal Information or other laws and regulations, when the customer does not cooperate with the necessary investigation, or when it cannot be confirmed that the request is made by the customer in person. Please note that a fee (JPY 1,000 per request) is charged for disclosure of personal data.

Article 7: Correction and Suspension of Use of Personal Data

1. When requested by a customer, in accordance with the Act on the Protection of Personal Information, to correct personal data on the grounds that it is untrue, the Company will, after confirming that the request is made by the customer in person, conduct the necessary investigation without delay, correct the personal information based on the results, and notify the customer to that effect.

2. When requested by a customer, in accordance with the Act on the Protection of Personal Information, to suspend the use of personal data on the grounds that it is being handled beyond the scope of the purpose of use announced in advance, or that it was obtained by deception or other wrongful means, the Company will, after confirming that the request is made by the customer in person, conduct the necessary investigation without delay, suspend the use of the personal information based on the results, and notify the customer to that effect.

3. When requested by a customer to erase the customer's personal data, if the Company determines that it needs to comply with the request, the Company will, after confirming that the request is made by the customer in person, erase the personal data and notify the customer to that effect.

4. If, as a result of the investigation and judgment set forth in Paragraphs 1 through 3, the Company decides not to correct, suspend the use of or erase personal data, the Company will notify the customer to that effect.

5. Notwithstanding Paragraphs 1 through 3, the Company will not correct or suspend the use of personal data when it is not obligated to do so under the Act on the Protection of Personal Information or other laws and regulations, when the customer does not cooperate with the necessary investigation, or when it cannot be confirmed that the request is made by the customer in person.

Article 8: Contact for Inquiries

For opinions, questions, complaints and other inquiries regarding the handling of user information, please contact the following.

HA-LU Inc.

Address: Chez Irene Bldg. 2F, 7-4-7 Akasaka, Minato-ku, Tokyo 107-0052, Japan

Email: info@ha-lu.jp

Article 9: Procedure for Changes to this Policy

The Company will change this Policy as necessary. However, when making changes to this Policy that require the customer's consent under laws and regulations, the changed Policy will apply only to customers who have consented to the change in the manner prescribed by the Company.

When changing this Policy, the Company will announce the effective date and content of the changed Policy by displaying it on the Company's website or by other appropriate methods, or will notify customers.

End

Established: April 30, 2024

This Policy is a translation of the original Japanese version. In the event of any discrepancy, the Japanese version shall prevail.